Disability Benefits – Court Error

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7^th Circuit Court of Appeals

Case Name: Carole Cheney v. Standard Insurance Company and Long Term Disability Insurance

Case No.: 15-1794

Officials: WOOD, Chief Judge, and MANION and ROVNER, Circuit Judges

Focus: Disability Benefits – Court Error

Court erred in interpreting insurance policy and made factual findings unsupported by evidence on the record.

“The court also thought that Cheney’s “reasonable expectations” of coverage were relevant and appropriate to consider, in light of ERISA’s purposes. Ruttenberg, 413 F.3d at 668 n.19 (citing Second, Fourth, Sixth, and Ninth Circuit precedent). No one disputes that “ERISA maintains the basic goal of ‘protecting employees’ justified expectations of receiving the benefits their employers promise them.’” Young v. Verizonʹs Bell Atl. Cash Balance Plan, 615 F.3d 808, 819 (7th Cir. 2010) (quoting Cent. Laborersʹ  Pension Fund v. Heinz, 541 U.S. 739, 743 (2004)) (allowing reformation of plan in favor of the plan be‐ cause scrivener’s error did not actually lead employees to expect greater benefits). But the reasonable‐expectation doctrine is related to actual reliance by the employee. We can find no evidence here from which the district court could have concluded that Cheney had an expectation, let alone relied on an expectation, of receiving disability benefits based on her 2010 earnings.”

Vacated and Remanded

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Attorney Derek A. Hawkins is the managing partner at Hawkins Law Offices LLC, where he heads up the firm’s startup law practice. He specializes in business formation, corporate governance, intellectual property protection, private equity and venture capital funding and mergers & acquisitions. Check out the website at www.hawkins-lawoffices.com or contact them at 262-737-8825.